0001413042-21-000770.txt : 20210910 0001413042-21-000770.hdr.sgml : 20210910 20210910161259 ACCESSION NUMBER: 0001413042-21-000770 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 4 CONFORMED PERIOD OF REPORT: 20210630 FILED AS OF DATE: 20210910 DATE AS OF CHANGE: 20210910 EFFECTIVENESS DATE: 20210910 FILER: COMPANY DATA: COMPANY CONFORMED NAME: PFS FUNDS CENTRAL INDEX KEY: 0001103243 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: N-CEN SEC ACT: 1940 Act SEC FILE NUMBER: 811-09781 FILM NUMBER: 211247208 BUSINESS ADDRESS: STREET 1: 1939 FRIENDSHIP DRIVE STREET 2: STE C CITY: EL CAJON STATE: CA ZIP: 92020 BUSINESS PHONE: 6185889700 MAIL ADDRESS: STREET 1: 1939 FRIENDSHIP DRIVE STREET 2: STE C CITY: EL CAJON STATE: CA ZIP: 92020 FORMER COMPANY: FORMER CONFORMED NAME: PREMIER FUNDS TRUST DATE OF NAME CHANGE: 20100119 FORMER COMPANY: FORMER CONFORMED NAME: WIRELESS FUND DATE OF NAME CHANGE: 20000113 0001103243 S000029372 Castle Focus Fund C000090233 Investor MOATX C000090234 Class C CASTX 0001103243 S000062392 Cargile Fund C000202401 Cargile Fund CFNDX 0001103243 S000065065 Castle Tandem Fund C000210708 Institutional TANDX 0001103243 S000068707 Conquer Risk Defensive Bull Fund C000219677 Conquer Risk Defensive Bull Fund CRDBX 0001103243 S000068708 Conquer Risk Managed Volatility Fund C000219678 Conquer Risk Managed Volatility Fund CRMVX 0001103243 S000068709 Conquer Risk Tactical Opportunities Fund C000219679 Conquer Risk Tactical Opportunities Fund CRTOX 0001103243 S000068710 Conquer Risk Tactical Rotation Fund C000219680 Conquer Risk Tactical Rotation Fund CRTBX N-CEN 1 primary_doc.xml X0404 N-CEN LIVE 0001103243 XXXXXXXX N-1A S000029372 C000090233 C000090234 S000062392 C000202401 S000065065 C000210708 S000068707 C000219677 S000068708 C000219678 S000068709 C000219679 S000068710 C000219680 PFS FUNDS 811-09781 0001103243 549300QPH5FGDXI8HN15 1939 FRIENDSHIP DRIVE, STE C EL CAJON 92020 US-CA US 619-588-9700 PFS Funds 1939 Friendship Drive, Suite C El Cajon 92020 619-588-9700 All accounts, books and documents required to be maintained by the Registrant pursuant to Section 31(a) of the Investment Company Act of 1940 and Rules 31a-1 through 31a-3 thereunder are maintained at the office of the Registrant except all those relating to the activities of the Fund's Custodian, Transfer Agent and Shareholder Servicing Agent. Mutual Shareholder Services, LLC 8000 Town Centre Drive, Suite 400 Broadview Heights 44147 440-922-0066 All accounts, books and documents required to be maintained by the Transfer Agent, Fund Accounting Agent and Shareholder Servicing Agent pursuant to Section 31(a) of the Investment Company Act of 1940 and Rules 31a-1 through 31a-3. US Bank, N.A. 425 Walnut Street Cincinnati 45202 513-632-4140 All accounts, books and documents all those relating to the activities of the Funds' Custodian. Castle Investment Management, LLC 277 S. Washington Street, Suite 335 Alexandria 22314 703-260-1921 Maintains records relating to its function as the investment adviser to the Castle Focus Fund and the Castle Tandem Fund. St. James Investment Company, LLC 3838 Oak Lawn Avenue, Suite 1414 Dallas 75219 214-484-7250 Maintains records relating to its function as the sub-adviser to the Castle Focus Fund. Tandem Investment Advisors, Inc. 145 King Street, Suite 400 Charleston 29401 843-720-3413 Maintains records relating to its function as the sub-adviser to the Castle Tandem Fund. Cargile Investment Management, Inc. 415 West Wall Street, Suite 2200 Midland 79701 432-617-1394 Maintains records relating to its function as the investment adviser to the Cargile Fund. Potomac Fund Management, Inc. 777 Brickell Ave, Suite #500-9455 Miami 33131 1-888-774-6679 Maintains records relating to its function as the investment adviser to the Conquer Risk Funds. N N N N-1A 13 Y JEFFREY R. PROVENCE N/A Y THOMAS H. ADDIS, III N/A N ALLEN C. BROWN N/A N GEORGE COSSOLIAS N/A N JULIAN G. WINTERS N/A 105 CANDLEWOOD ROAD, SUITE C ROCKY MOUNT 27804 XXXXXX N N N N N N N RAFFERTY CAPITAL MARKETS, LLC 008-40605 000023682 N/A N N COHEN & COMPANY, LTD. 925 N/A N N N N N N N CASTLE FOCUS FUND S000029372 549300TSNG2XMCUGTB05 N 2 0 0 N/A Y N Y N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N CASTLE INVESTMENT MANAGEMENT, LLC 801-71363 000153464 N/A N ST. JAMES INVESTMENT COMPANY, LLC 801-61779 000124777 N/A N N MUTUAL SHAREHOLDER SERVICES, LLC 084-05821 549300TSNG2XMCUGTB05 N N N FIS N/A N N US BANK, N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N MUTUAL SHAREHOLDER SERVICES, LLC 549300TSNG2XMCUGTB05 N N N PREMIER FUND SOLUTIONS, INC. N/A Y N N Charles Schwab 008-16514 000005393 549300ZP8XN77GK5BS04 1500 1500 0 N 69096902.26 N N N N CASTLE TANDEM FUND S000065065 549300DEPAKKV8412S11 N 1 0 0 N/A N N Y N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N CASTLE INVESTMENT MANAGEMENT, LLC 801-71363 000153464 N/A N Tandem Investment Advisors, Inc. 801-57846 000109392 N/A N N MUTUAL SHAREHOLDER SERVICES, LLC 084-05821 549300TSNG2XMCUGTB05 N N N FIS N/A N N US BANK, N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N MUTUAL SHAREHOLDER SERVICES, LLC 549300TSNG2XMCUGTB05 N N N PREMIER FUND SOLUTIONS, INC. N/A Y N N DASH FINANCIAL TECHNOLOGIES LLC 008-52503 000104031 549300VYG4AYVBIDN394 2511 CHARLES SCHWAB 008-16514 000005393 549300ZP8XN77GK5BS04 5 2516 0 N 31169332 N N N N CARGILE FUND S000062392 549300DBZNEXVZ7EXT45 N 1 0 0 N/A Y N Y N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) N N N N CARGILE INVESTMENT MANAGEMENT, INC. 801-64513 000116982 N/A N MUTUAL SHAREHOLDER SERVICES, LLC 084-05821 549300TSNG2XMCUGTB05 N N N FIS N/A N N US BANK, N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N MUTUAL SHAREHOLDER SERVICES, LLC 549300TSNG2XMCUGTB05 N N N PREMIER FUND SOLUTIONS, INC. N/A Y N N CEROS FINANCIAL SERVICES, INC. 008-47955 000037869 549300N2YQ0P5G0WE562 51614 51614 0 N 36370463 N N N N Conquer Risk Defensive Bull Fund S000068707 549300L3P3MK4DLWP178 Y 1 0 0 N/A Y N Y N N/A N/A N N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N Potomac Fund Management, Inc. 801-31311 000105413 N/A N MUTUAL SHAREHOLDER SERVICES, LLC 084-05821 549300TSNG2XMCUGTB05 N N N FIS N/A N N US BANK, N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N MUTUAL SHAREHOLDER SERVICES, LLC 549300TSNG2XMCUGTB05 N N N PREMIER FUND SOLUTIONS, INC. N/A N N N CEROS FINANCIAL SERVICES, INC. 008-47955 000037869 549300N2YQ0P5G0WE562 205756 205756 0 N 128728510 N N N N Conquer Risk Managed Volatility Fund S000068708 549300XPZMG0C2BFLP55 Y 1 0 0 N/A Y N Y N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N Potomac Fund Management, Inc. 801-31311 000105413 N/A N MUTUAL SHAREHOLDER SERVICES, LLC 084-05821 549300TSNG2XMCUGTB05 N N N FIS N/A N N US BANK, N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N MUTUAL SHAREHOLDER SERVICES, LLC 549300TSNG2XMCUGTB05 N N N PREMIER FUND SOLUTIONS, INC. N/A N N N CEROS FINANCIAL SERVICES, INC. 008-47955 000037869 549300N2YQ0P5G0WE562 34523 34523 0 N 22931443 N N N N Conquer Risk Tactical Opportunities Fund S000068709 5493000SLMKDUD0NEP61 Y 1 0 0 N/A Y N Y N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N Potomac Fund Management, Inc. 801-31311 000105413 N/A N MUTUAL SHAREHOLDER SERVICES, LLC 084-05821 549300TSNG2XMCUGTB05 N N N FIS N/A N N US BANK, N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N MUTUAL SHAREHOLDER SERVICES, LLC 549300TSNG2XMCUGTB05 N N N PREMIER FUND SOLUTIONS, INC. N/A N N N CEROS FINANCIAL SERVICES, INC. 008-47955 000037869 549300N2YQ0P5G0WE562 81377 81377 0 N 33788149 N N N N Conquer Risk Tactical Rotation Fund S000068710 5493004QSZG082ITYI26 Y 1 0 0 N/A Y N Y N N/A N/A N/A Rule 32a-4 (17 CFR 270.32a-4) Y Y N N Potomac Fund Management, Inc. 801-31311 000105413 N/A N MUTUAL SHAREHOLDER SERVICES, LLC 084-05821 549300TSNG2XMCUGTB05 N N N FIS N/A N N US BANK, N.A. 6BYL5QZYBDK8S7L73M02 N N Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1)) N MUTUAL SHAREHOLDER SERVICES, LLC 549300TSNG2XMCUGTB05 N N N PREMIER FUND SOLUTIONS, INC. N/A N N N CEROS FINANCIAL SERVICES, INC. 008-47955 000037869 549300N2YQ0P5G0WE562 63393 63393 0 N 35378482 N N N N false false true false false false INTERNAL CONTROL RPT 2 castlencen.htm Internal Control Letter



REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


To the Shareholders of Castle Focus Fund and Castle Tandem Fund and

Board of Trustees of PFS Funds


In planning and performing our audit of the financial statements of Castle Focus Fund and Castle Tandem Fund (the “Funds”), each a series of PFS Funds, as of and for the year ended June 30, 2021, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Funds’ internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Funds’ internal control over financial reporting.  Accordingly, we express no such opinion.


The management of the Funds is responsible for establishing and maintaining effective internal control over financial reporting.  In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.  A fund’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP).  A fund’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund’s assets that could have a material effect on the financial statements.  


Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.  Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.


A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis.  A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Funds’ annual or interim financial statements will not be prevented or detected on a timely basis.


Our consideration of the Funds’ internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the PCAOB.  However, we noted no deficiencies in the Funds’ internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of June 30, 2021.


This report is intended solely for the information and use of management and the Board of Trustees of the Funds and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.



/s/Cohen & Company, Ltd.

COHEN & COMPANY, LTD.

Milwaukee, Wisconsin

August 25, 2021




INTERNAL CONTROL RPT 3 cargilencen.htm Internal Control Letter



REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


To the Shareholders of Cargile Fund and

Board of Trustees of PFS Funds


In planning and performing our audit of the financial statements of Cargile Fund (the “Fund”), a series of PFS Funds, as of and for the year ended June 30, 2021, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund’s internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting.  Accordingly, we express no such opinion.


The management of the Fund is responsible for establishing and maintaining effective internal control over financial reporting.  In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.  A fund’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP).  A fund’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund’s assets that could have a material effect on the financial statements.  


Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.  Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.


A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis.  A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Fund’s annual or interim financial statements will not be prevented or detected on a timely basis.


Our consideration of the Fund’s internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the PCAOB.  However, we noted no deficiencies in the Fund’s internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of June 30, 2021.


This report is intended solely for the information and use of management and the Board of Trustees of the Fund and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.



/s/Cohen & Company, Ltd.

COHEN & COMPANY, LTD.

Milwaukee, Wisconsin

August 25, 2021




INTERNAL CONTROL RPT 4 conquerriskncen.htm Internal Control Letter



REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


To the Shareholders of the Conquer Risk Funds and

Board of Trustees of PFS Funds


In planning and performing our audit of the financial statements of Conquer Risk Defensive Bull Fund, Conquer Risk Managed Volatility Fund, Conquer Risk Tactical Opportunities Fund, and Conquer Risk Tactical Rotation Fund (the “Funds”), each a series of PFS Funds, as of and for the year ended June 30, 2021, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Funds’ internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Funds’ internal control over financial reporting.  Accordingly, we express no such opinion.


The management of the Funds is responsible for establishing and maintaining effective internal control over financial reporting.  In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls.  A fund’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP).  A fund’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the fund; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the fund are being made only in accordance with authorizations of management and trustees of the fund; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a fund’s assets that could have a material effect on the financial statements.  


Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.  Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.


A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis.  A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the Funds’ annual or interim financial statements will not be prevented or detected on a timely basis.


Our consideration of the Funds’ internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control that might be material weaknesses under standards established by the PCAOB.  However, we noted no deficiencies in the Funds’ internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of June 30, 2021.


This report is intended solely for the information and use of management and the Board of Trustees of the Funds and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.



/s/Cohen & Company, Ltd.

COHEN & COMPANY, LTD.

Milwaukee, Wisconsin

August 25, 2021